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Brad Gould

Mr. Gould practices in the area of federal income, estate, and gift tax law and business succession planning. He represents businesses and business owners in all types of business and tax matters, including choice of entity, mergers and acquisitions, reorganizations, and other general business matters. Mr. Gould represents individuals, businesses and fiduciaries before the Internal Revenue Service and also counsels clients on estate and wealth preservation planning matters. Additionally, he represents trustees, personal representatives and family members in controversies regarding wills, trusts and estates. Mr. Gould is a Certified Public Accountant.

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Additional Representative Experience

Significant Representations

Represented a married couple that operated an out of state, luxury rental business before the IRS. The IRS argued that the losses from the business were passive and assessed over $500,000 in taxes and penalties. After establishing a strong case before IRS Appeals that the spouse operating the business qualified as a real estate professional, the IRS conceded on all counts and permitted the deduction of all of the losses.

Represented a closely-held S corporation operating a large cattle ranch with the tax-free split-up. The corporation was owned and operated by two generations of ranchers consisting of several siblings and their children. As the younger generation became involved with management, discrete family groups established different goals for the direction of the company. In order to avoid a costly and divisive lawsuit, a plan was developed to divide the corporation in tax –free reorganization and avoid the millions of dollars in state and federal income taxes that would normally be due when a corporation distributes its assets to its shareholders.

Represented a family in one of the early voluntary offshore disclosure filings with the IRS OVDP program. After the death of their parents, our clients learned one of their parents owned an undisclosed multi-million dollar offshore bank account. In addition to failing to report the account on an FBAR, the parent omitted all of the income from the account for income tax purposes and the account was not reported for estate tax purposes on either parent’s estate tax return. Through participating in the OVDP program, we helped our clients mitigate their tax exposure, including utilizing an estate tax deduction for the OVDP penalty and avoiding a criminal investigation.

Represented the descendants of a man suffering from dementia who was secluded from his family for over a decade by his second wife, during which time she methodically transferred his $15 million estate to her and her descendants. After extensive discovery and mediation, the man’s heirs recovered the assets they would have received under his will as if his wife had not taken them during his life.

Professional and Civic Activities

Florida Bar Association

Tax Section

Real Property, Probate and Trust Law Section

American Bar Association

Tax Section - Member

S Corporation Committee - Vice Chair

American Institute of Certified Public Accountants

Florida Institute of Certified Public Accountants (FICPA)

Board of Directors/ Executive Committee, 2015 - present

Council/Board of Governors, 2012 - present

University of Florida Annual Accounting Conference

Committee Member

Committee Chairman, 2009

FICPA - Sailfish Chapter

LGBT Task Force

Chair

St. Lucie County Bar Association

Member and Past Treasurer

St. Lucie County Chamber of Commerce

Charitable and Pro Bono Service

Big Brothers Big Sisters of St. Lucie, Indian River and Okeechobee Counties

Board Member, 2005-present

Past Chair, 2008

Parent Academy of St. Lucie County

Founding Board Member, 2010-present

Chair, 20110-2015

Education

Juris Doctor: University of Florida Levin College of Law, Gainesville, Florida, with honors, 2001

Master of Accounting: University of Florida, Gainesville, Florida, 1998

Bachelor of Science in Accounting: University of Florida, Gainesville, Florida, withhonors, 1998